The short answer
Three things need to happen before a PPN 006 plan is finished:
- The board approves it. Your board of directors, or the equivalent management body if you don't have a board, reviews the plan and agrees it.
- A director signs the declaration on behalf of the organisation, giving their name and position.
- The plan is dated. The date of board approval is the plan's publication date.
That is it. There is no box for an auditor, an accredited assessor or a consultant. Whoever prepared the figures, whether that is your finance manager, an operations lead or an outside adviser, the responsibility for the plan sits with the board.
What the director is signing
The declaration in the government template is a short statement. In plain English, the director confirms that:
- the plan has been completed in line with PPN 006 and the technical standard for Carbon Reduction Plans;
- emissions have been calculated following the GHG Protocol corporate standard, using the UK government's conversion factors for company reporting;
- Scope 1 and 2 have been reported in line with SECR requirements, and the required Scope 3 categories in line with the technical standard;
- the board, or equivalent management body, has reviewed and signed off the plan on the stated date.
So before signing, the director should be comfortable that the method is right, not just that the totals look sensible. That doesn't mean checking every calculation. It means asking a few good questions.
Questions a director should ask before signing
| Question | What a good answer looks like |
|---|---|
| Which conversion factors did we use? | The DESNZ set for each reporting year, not one set for every year |
| Are all five Scope 3 categories covered? | A figure for 4, 5, 6, 7 and 9, or a stated reason one doesn't apply |
| Where did we estimate? | A short list, such as commuting from a sample survey, with the method explained in the plan |
| Why this baseline year? | A full year we can evidence, with the reason written down |
| Is the green tariff shown honestly? | Scope 2 reported location-based, with any market-based figure clearly labelled |
| Are our reduction projects real? | Specific projects with years, that the business has agreed to fund |
If you are unsure about the Scope 3 categories, our post on the five categories PPN 006 asks for is a quick read. For the baseline, see how to pick a baseline year, and for electricity, see location-based vs market-based.
If you don't have a board of directors
The declaration refers to the board of directors "or equivalent management body", so the plan can be approved by whoever governs your organisation. For a partnership or LLP that is usually the partners or members who manage the business; for a charity, its trustees. One of that body's senior members then signs and gives their position. If a tender sets out its own sign-off rules, follow those.
Recording the approval
It is good practice to minute the approval at a board meeting, and to keep the working papers behind the figures: bills, fuel card statements, the commuting survey and your waste contractor's reports. Nobody is required to audit them, but a buyer may ask how a figure was reached, and next year's update is much quicker if you can see what you did last time.
Signing again each year
A Carbon Reduction Plan is not a one-off. The technical standard asks for it to be reviewed and updated within six months of the end of your financial year, with new board approval each time. Each version gets its own date, and the new plan replaces the old one on your website. See how to publish your Carbon Reduction Plan.
How Carbon Recycling helps
The Carbon Reduction Plan in Carbon Recycling includes the standard declaration and fields for the board approval, the signing director's name and position, and the approval date. Until all of those are recorded, the plan carries a clear "Draft" banner, so an unsigned version can't be mistaken for the final one. Our PPN 006 guide covers the rest of the plan.